Importing Goods Into Quebec: GST/QST Rules, Customs Documentation, and ITC/ITR Eligibility

Introduction

Businesses importing goods into Quebec — whether from the U.S., Europe, Asia, or any other jurisdiction — face complex GST/QST rules involving customs duties, import taxes, brokerage fees, and documentation requirements. Many SMEs, Amazon sellers, e-commerce stores, wholesalers, and manufacturers make mistakes on GST/QST during importation, leading to denied ITCs/ITRs, reassessments, and penalties.

This guide explains how GST/QST apply when importing goods, how to document your imports properly, how to claim input tax credits (ITCs) and input tax refunds (ITRs), and what Revenu Québec and CRA auditors look for during import audits.

Legal and Regulatory Framework

GST and QST on imported goods are governed by the Excise Tax Act (ETA) and the Quebec Taxation Act (TAA).

GST at Importation

Under ETA s. 212, all commercial goods imported into Canada are subject to 5% GST, collected by the Canada Border Services Agency (CBSA) at the time of import.

QST on Imported Goods

Under TAA ss. 53–59, businesses registered for QST must self-assess QST on imported goods unless the goods are imported into Quebec through a customs broker that remits QST on your behalf.

Key Documentation

Businesses must retain:

• B3 Customs Coding Forms

• Commercial invoices

• Bills of lading

• Proof of payment

• Brokerage statements

• Cargo release documents

• Import permits (if applicable)

Without these documents, GST/QST claims may be denied.

ITC/ITR Eligibility

To claim ITCs (GST) and ITRs (QST), the importer must:

• be properly registered for GST and QST

• have proper import documentation

• have paid the import GST/QST

• import goods for commercial, taxable activities

Goods imported for exempt activities (healthcare, financial services, residential rentals) may not generate ITCs/ITRs.

Key Court Decisions

1. CBS Canada Holdings Co., 2020 TCC — Missing import documents deny ITCs

The court held that a business cannot claim ITCs without proper CBSA documentation, even if it can prove business use. Documentation is mandatory.

2. Allied Beauty Corp. v. RQ, 2019 QCCQ — QST must be self-assessed

A Quebec importer failed to self-assess QST on goods imported via a U.S. supplier. The court confirmed that QST is payable even if the supplier is foreign.

3. Perfumes L.T. Inc., 2018 — Incorrect importer of record

The corporation claimed ITCs for GST paid at importation, but CBSA documents listed another entity as the importer. Court denied ITCs.

4. RQ v. Distribution X Inc., 2022 — Broker errors do not remove liability

Brokerage mistakes still leave the business responsible for GST/QST unless fully corrected.

These decisions emphasize strict adherence to documentation, importer-of-record accuracy, and proper tax self-assessment.

Why CRA and Revenu Québec Target Importers

Authorities focus heavily on importers because:

1. High risk of unreported GST/QST
   Many businesses forget to self-assess QST or misclassify import GST.

2. Frequent errors by customs brokers
   Businesses often assume the broker handled everything — auditors know this is rarely true.

3. Large volumes of imports
   Especially for e-commerce sellers, Amazon FBA, Shopify stores, and wholesalers.

4. Proof problems
   Missing customs forms lead to denied ITC/ITR claims.

5. Transfer pricing concerns
   Undervalued invoices or related-party pricing may trigger further review.

Auditors examine import data through CBSA import logs, which they can obtain through a database request.

Mackisen Strategy: How We Protect Import-Based Businesses

We apply a structured import-tax compliance approach to prevent denied ITCs/ITRs and audit penalties.

1. Import Documentation Audit

We review:

• all B3 forms

• broker statements

• invoices

• cargo release notices

• proof of GST/QST paid

We fix gaps before any audit.

2. Correcting Importer-of-Record Errors

If documents list the wrong importer, we help file adjustments with):

• CBSA (Corrections/Refunds)

• Revenu Québec (QST adjustments)

This restores eligibility for ITCs/ITRs.

3. Organizing Taxable vs Non-Taxable Imports

We verify which goods produce ITCs/ITRs and which do not.

4. Preparing for Revenu Québec and CRA Audits

We handle:

• all auditor communication

• import reconciliations

• explanations of classification

• sourcing documentation

• proof of commercial activities

5. Filing Voluntary Disclosures

Where QST was never self-assessed, we file voluntary disclosure to reduce penalties.

Real Client Experience

A Montreal-based Amazon FBA importer faced a reassessment for denied ITCs/ITRs because the customs broker mistakenly listed the supplier as the importer.

Mackisen:

1. Reconstructed two years of import data.

2. Filed CBSA B2 adjustments to correct importer-of-record details.

3. Submitted revised GST/QST filings.

4. Successfully claimed over $42,000 in ITCs/ITRs previously denied.

5. Prevented an additional $28,000 in penalties.

Outcome: The audit closed with no balance owing.

Common Questions

Can I claim ITCs without the B3 form?

No. CRA requires original or digital customs documents.

Are brokerage fees GST/QST deductible?

Yes, if they relate to commercial activities.

Does QST apply if my supplier is outside Canada?

Yes. You must self-assess QST even if the supplier is foreign.

Do Amazon FBA sellers need import documentation?

Absolutely. Even if Amazon handles logistics, you are still the importer of record.

What if the broker made a mistake?

You remain responsible unless corrected through CBSA adjustment.

Why Mackisen

With more than 35 years of combined CPA experience, Mackisen CPA Montreal helps businesses stay compliant while recovering the taxes they’re entitled to. Whether you’re filing your first GST/QST return or optimizing multi-year refunds, our expert team ensures precision, transparency, and protection from audit risk.

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Importing into Quebec requires precise GST/QST compliance. Learn documentation rules, ITC eligibility, self-assessment obligations, and audit risks.